This is a complaint I filed this morning with the Los Angeles City Ethics Commission alleging that business improvement district consultant Tara Devine was acting as a lobbyist within the meaning of the Los Angeles Municipal Lobbying Ordinance but failed to register with the City as required. It's a still-untested theory, since there are many BID consultants and none of them except for Larry Kosmont have, as far as I can see, ever registered. But that doesn't mean that the law doesn't require them to do so. At least Larry Kosmont thinks it does, and he ought to know. It's a tricky proposition to prove that someone's required to register, since one element of the requirement is that they be paid for thirty or more hours of lobbying activity over three consecutive months. With most cases it's just too hard to collect evidence for that. However, since BID consultants do most of their lobbying in direct contact with members of the City Clerk's office and the Council District in which their proposed BID is located, it may be possible to gather enough evidence in these specific cases using the California Public Records Act. That's what I've tried to do here, anyway. This is the second such complaint I've filed against Devine. The first was based on her work for the Venice Beach BID and may be found here.